What we want to achieve: packaging waste recycling targets
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What we want to achieve: packaging
waste recycling targets
4.1 This section covers:
• The overarching framework for future packaging targets
• Business recycling targets for 2023 to be introduced under the 2007 Packaging
Waste Regulations
• Packaging recycling rates to 2030; that is the combined recycling rate for packaging
in scope of Extended Producer Responsibility and deposit return schemes
• Proposed packaging recycling targets to 2030 for packaging in scope of Extended
Producer Responsibility
• New targets (closed loop and reuse/refill)
Framework for future packaging targets
4.2 Government has developed a framework for packaging targets, set out below. It
has been developed in discussion with stakeholders. It focuses on increasing the recycling
of packaging initially, acknowledging that good progress has been made but there is more
to be done, whilst signalling Government’s clear desire to see greater circularity and more
reusable and refillable packaging in use.
1. Targets will be set on producers obligated under the Extended Producer
Responsibility scheme for packaging that is in scope of Extended Producer
Responsibility. Collection targets have been set for the Scottish deposit return
scheme and collection targets will be set for the England, Wales and Northern
Ireland deposit return scheme.
2. Overall packaging recycling rates will be reported for the UK and for England,
Northern Ireland, Scotland and Wales separately, taking account of material
collected and recycled under the Extended Producer Responsibility and the deposit
return schemes.
3. Extended Producer Responsibility recycling targets for six packaging materials
(plastic, card, steel, aluminium, glass, wood) will be set initially to 2030. These
targets will be established on a UK-wide basis and will be required to be met in
England, Northern Ireland, Scotland and Wales.
4. Recycling targets will be introduced for additional packaging materials where
targets are identified as an effective tool to contribute to the delivery of desired
outcomes. The first consideration is to establish recycling targets for fibre-based
composite packaging including disposable paper cups.
5. Introduction of ‘closed loop’ recycling targets where required to drive the supply of
better-quality material to end markets. A re-melt target for glass will be retained.
Targets for other materials will be considered in 2025, allowing time for markets to
respond to the changes introduced through Extended Producer Responsibility,
deposit return schemes and the Plastic Packaging Tax.6. Introduction of targets to incentivise adoption of re-fillable and re-usable packaging
systems will be considered further by Government. Government will make
proposals for reuse/refill targets by the end of 2023, with the intention of introducing
targets or obligations from 2025.
Recycling targets for 2023
4.3 Packaging waste recycling targets under the current regulations are in place to
2022. These targets are shown in Table 1 and typically are referred to as business
targets 1. As it is proposed, subject to this consultation, that the new Extended Producer
Responsibility scheme will be phased in from 2023 and operate alongside the existing
producer responsibility system in 2023, recycling targets for 2023 will be required under
the current regulations to ensure continued functioning of the Packaging Recovery Note
(PRN) evidence system. Government proposes that for 2023 the targets are held at the
rates agreed for 2022. The Scottish deposit return scheme will have commenced in 2022
and will be accompanied by scheme-specific targets; therefore, material collected through
the Scottish deposit return scheme will not contribute to the business packaging waste
recycling targets set for 2023 (to be achieved through the current packaging producer
responsibility system). Government also recognises that 2023 will be a year of transition
to the new Extended Producer Responsibility system and some producers will pick up new
obligations in respect of the payment of fees for household packaging waste.
Table 1 - 2021 and 2022 business recycling targets for the current packaging producer
responsibility scheme.
2021 Overall 2022 Overall recycling
Business targets recycling rate Business targets rate
Paper 79.0% 67.8% 83.0% 71.5%
Glass 81.0% 69.1% 82.0% 70.8%
Aluminium 66.0% 56.0% 69.0% 58.0%
Steel 86.0% 77.3% 87.0% 77.6%
Plastic 59.0% 49.8% 61.0% 51.5%
Wood 35.0% 36.3% 35.0% 36.9%
Overall Recycling 76.0% 66.3% 77.0% 67.6%
1 Under the current Packaging Waste Regulations (2007) obligated producers are required to meet annual
recycling targets (known as business packaging waste recycling targets), with total UK packaging waste
recycling rates reported annually by Defra.
2 of 16Note – these are the minimum rates the material specific targets would achieve and do not take account of
the general recycling requirement.
4.4 The final compliance year of the current packaging producer responsibility system
will end on 31 December 2023. We anticipate that the compliance year for Extended
Producer Responsibility targets will be the calendar year (i.e. January to December) with
new recycling targets for Extended Producer Responsibility in place from January 2024.
Overall packaging recycling rates to 2030
4.5 Under the current Packaging Waste Regulations (2007) obligated producers are
required to meet annual recycling targets (known as business targets), with total UK
packaging waste recycling rates reported annually by Defra. In future producer
responsibility for packaging will be managed through three producer led schemes
(Extended Producer Responsibility UK, Scottish deposit return scheme and England,
Wales and Northern Ireland deposit return scheme), each introduced through separate
regulations and with separate targets 2.
4.6 Once new data reporting requirements on producers have been established and
packaging placed on the market data is available for England, Northern Ireland, Scotland
and Wales overall packaging waste recycling rates by nation (that is packaging waste
recycled through Extended Producer Responsibility plus that collected and recycled
through deposit return schemes) will be reported by the UK Government and each of the
Devolved Administrations annually.
4.7 Our initial analysis estimates an overall UK packaging recycling rate of 78% in
2030. This is based on the proposals for Extended Producer Responsibility set out in this
document and is based on modelling that Extended Producer Responsibility will be
introduced alongside an all-in England, Wales and Northern Ireland deposit return scheme
and the collection of a consistent set of packaging materials for recycling from households
and businesses in all parts of the UK. The combined impact of implementing these
measures is an estimated 16 percentage-point increase in recycling by 2030, compared to
no change 3. For each material the estimated recycling rate for 2030, shown in Table 2,
exceeds the equivalent target set by the European Packaging and Packaging Waste
2 It is proposed for the England, Wales and Northern Ireland deposit return scheme that collection targets will be set in
the regulations with the obligation to meet these targets placed on the Deposit Management Organisation. The Scottish
deposit return scheme regulations set collection targets.
3 The difference in the baseline ‘no change’ packaging recycling rate (61% in 2030) and the estimated packaging waste
recycling rate for 2022 of 67% (Table 1) is due to different assumptions regarding placed on the market packaging
(POM). POM tonnages assumed for the Impact Assessment are the “high POM” estimates from the WRAP/Valpak
Packflow Material reports, derived by applying the upper error margins presented in the reports to the central POM
scenario in the Impact Assessment. This results in an additional 1 million tonnes of packaging POM compared to the
total POM estimate used to determine current packaging recycling rates. A higher total POM has been assumed in the
Impact Assessment to address concerns that total packaging is under-estimated currently.
3 of 16Directive. The overall packaging recycling rates that are considered achievable will
depend on the final design of each policy.
Table 2 - Modelled UK packaging waste recycling rates in 2025 and 2030
2025 2030
No DRS + Percentage No DRS + Percentage 2030
change Consistency point change Consistency Point PPWD
+EPR increase + EPR increase Targets 4
Plastic 42% 51% +9% 42% 62% +20% 55%
Wood 38% 39% +1% 38% 39% +1% 30%
Aluminium 57% 69% +12% 57% 69% +12% 60%
Steel 83% 88% +5% 83% 92% +9% 80%
Paper/card 70% 81% +11% 70% 86% +15% 85%
Glass 69% 92% +23% 69% 93% +25% 75%
Total 61% 73% +11% 61% 78% +16% 70%
Note: this analysis assumes the introduction of an England, Wales and Northern Ireland deposit return
scheme, Extended Producer Responsibility and Consistency (in England). The analysis does not include the
contribution from Scottish deposit return scheme material.
Extended Producer Responsibility packaging waste recycling targets to
2030
4.8 Under the new Extended Producer Responsibility regulations, the obligation to meet
targets will be placed on those producers who place packaging on the UK market and who
are obligated to fund the full net costs of managing this packaging (as set out in Section
5) 5. Our proposals for obligated producers would see those businesses selling unfilled
packaging to businesses below the de-minimis threshold take on the obligation for this
packaging. This means that most packaging would be in scope and as a result we expect
4 Packaging and Packaging Waste Directive targets that apply to EU Member States
5 The Environment Act 95 (s.93-96) producer responsibility powers, which will be repealed and updated by
the Environment Bill clause 49 and schedule 4), require obligations to be placed on producers. Producers
however can discharge their obligations by joining a compliance scheme.
4 of 16there would no longer be a need to set business recycling targets as required by the
current regulations.
4.9 The Extended Producer Responsibility regulations will set recycling targets for
packaging materials in scope of Extended Producer Responsibility. In the 2019
consultation it was proposed that targets would be set for 2025 and 2030, with a
requirement on the UK Government and the Devolved Administrations to report annually
on recycling rates in order to monitor progress towards these targets. Following feedback
from stakeholders, including the Advisory Committee on Packaging, Government
proposes that Extended Producer Responsibility targets are set on an annual basis.
4.10 Table 3 sets out the proposed material targets for 2024 and 2030. Annual targets
for the years 2025 to 2029 would be set on a trajectory to reach the 2030 target rate. The
overall recycling rate is derived from the individual material rates. Consideration of issues
relevant to the individual material streams are discussed below. The targets have been
derived from an analysis of the impact of key packaging Extended Producer Responsibility
measures. The analysis assumes that an all in England, Wales and Northern Ireland
deposit return scheme and consistent collections will be introduced alongside Extended
Producer Responsibility as outlined above. The rationale, key assumptions and results of
this analysis are described in the accompanying Impact Assessment 6.
4.11 Our intention is that for the purpose of measuring the achievement of recycling
targets, that packaging waste recycled is calculated as the weight of packaging that has
become waste which, having undergone all checking, sorting and other operations
necessary to remove waste materials that are not targeted by the subsequent
reprocessing operation and to ensure quality material, enters the final reprocessing
operation and is reprocessed into new products, materials or substances. In other words,
the point of measurement is when the waste enters the final reprocessing operation. The
reporting and evidence requirements to demonstrate packaging waste has reached this
stage are discussed in Sections 8 and 11.
4.12 We do not intend to set an overall recycling target for each year, rather the
material specific targets will deliver the overall packaging waste recycling rate. This means
that producers will not have a “general recycling obligation” as under the current
regulations. The general recycling obligation was intended to ensure a minimum level of
recycling when the material specific targets were relatively low. As the material specific
targets have increased, closing the gap on the ‘overall recycling level’, the need for the
general requirement has declined.
6 Please see accompanying Impact Assessment
5 of 16Table 3 - Proposed recycling targets for packaging in scope of Extended Producer
Responsibility
EPR Packaging Materials 2024 2030
Plastic 41% 56%
Wood 38% 39%
Aluminium* 30% 30%
Steel* 85% 92%
Paper/Card 76% 85%
Glass 71% 81%
Recycling rate delivered by targets 63% 73%
Notes:
i. Excludes materials proposed to be in scope of deposit return schemes (Scottish and England, Wales and
Northern Ireland)
ii. Includes some provision for metals recovered for recycling from incinerator bottom ash*
iii. Targets are not comparable with the recycling rates achieved under the current scheme
Aluminium
4.13 Table 3 shows the recycling rate for aluminium packaging in scope of Extended
Producer Responsibility. Most aluminium packaging is drinks cans; these are in scope of
the Scottish deposit return scheme and proposed to be in scope of the England, Wales
and Northern Ireland deposit return scheme. The assumption in the Impact Assessment is
that a total of 229kt of aluminium packaging will be placed on the market in 2023, with 98kt
being non-can and therefore in scope of Extended Producer Responsibility. This is
consistent with industry estimates of tonnage for drinks cans in 2019 (132kt of drinks can
material) 7.
4.14 Our analysis assumes that the tonnage, once cans have been removed, consists of
packaging that currently does not have a high recycling rate (such as aerosols and foils)
mainly because these are not collected for recycling by all local authorities. This is the
reason for the low recycling rate. If these items (including aerosols, foils, closures) are
required to be collected from households by all local authorities as proposed, this would
see the recycling rate increase and hence a higher target for aluminium could be set. This
additional analysis will be undertaken for the final impact assessment and we will continue
to engage with the sector as we undertake this analysis.
7 Valpak Packflow Report 2020 – Covid-19 phase 1: Metals
6 of 16Glass
4.15 A high proportion of glass packaging is drinks containers which are in scope of the
Scottish deposit return scheme and proposed to be in scope of the England, Wales and
Northern Ireland deposit return scheme (84% of glass packaging placed on the market is
glass bottles); otherwise glass packaging is mainly used for food products such as
condiments, sauces and preserves. This packaging is readily recyclable supporting a high
target being set for non-bottle glass packaging.
4.16 There has been a ‘re-melt’ target for glass for several years to incentivise more
glass into re-melt applications (e.g. container glass back into containers), thereby
encouraging better quality and greater environmental benefit than alternative uses such as
aggregate. The re-melt target is 72% for 2021 and 2022.
Plastic
4.17 Polyethylene terephthalate (PET) drinks containers which are in scope of the
Scottish deposit return scheme and proposed to be in scope of the England, Wales and
Northern Ireland deposit return scheme would not be subject to Extended Producer
Responsibility and hence would not contribute to Extended Producer Responsibility plastic
packaging recycling targets; all other plastic packaging that is recycled would. The Impact
Assessment assumes policy measures introduced under Extended Producer
Responsibility would reduce the use of hard to recycle plastic packaging and that plastic
pots, tubs and trays would be collected for recycling by all local authorities and from
businesses. These measures would contribute to higher recycling of plastic packaging.
However, a key consideration in the setting of future recycling targets for plastic packaging
is the contribution from plastic films and flexibles. With around a third of the 2.4mt of
plastic packaging being films and flexibles and around half of this consumer packaging,
the recyclability of these materials and their collection for recycling is a key consideration
in the setting of future targets.
4.18 Conservative assumptions are made in the Impact Assessment analysis regarding
the introduction of films to recycling collections and likely capture rates. Depending on final
policy decisions regarding the collection of plastic films and flexibles for recycling, it may
be feasible to set higher plastic packaging recycling targets.
Wood
4.19 The business recycling target for wood was set at 48% for 2020, however, following
discussions with producers, and feedback to the 2019 consultation, it was reduced to 35%
for 2021 and 2022. This is still 10% higher than the equivalent European Union target. It
was the view of producers that the target for 2020 had been set too high, resulting in price
spikes for wood Packaging Recycling Notes in 2018 as the market responded. Most wood
recyclers, however, did not share this view. Lowering the target for 2021 and 2022 was
intended to be a compromise between achievability and ambition.
4.20 Sources suggest that the higher wood recycling rates were achieved by drawing
waste packaging wood from the biomass and energy from waste sectors rather than
7 of 16incentivising additional collection for recycling. The demand for wood Packaging Recycling
Notes driving higher prices, to the point at which the incentive to recycle was greater than
the renewables incentives. The environmental case for a higher wood target was limited,
as it did not lead to additional carbon benefits or more collection of wood packaging, but
rather re-directed waste wood from other existing activities.
4.21 Government is not against higher targets in the future, however we would want to
ensure that the targets lead to new collection systems being established, and that wood
packaging waste is sent to the most environmentally beneficial use, including longer term
applications (such as panels). We also do not want recycling targets to dis-incentivise
greater re-use. A balance therefore needs to be established between a suitably ambitious
recycling target and one that delivers the best environmental outcome for waste wood
packaging. The analysis for the Impact Assessment shows a modest 1% increase against
the baseline, however Government acknowledges that further work is required before
confirming future targets. A cross sector working group has been established to take
forward this work and Government will engage with this group prior to finalising target
proposals for wood.
Steel
4.22 The recycling target proposed for steel packaging is 92% by 2030. This reflects the
already high recycling rate for steel; that most steel packaging will be in scope of Extended
Producer Responsibility (e.g. canned food, pet food, some aerosols, DIY goods) and that
the infrastructure is in place to capture this material for recycling. Compared with
aluminium only a small proportion of drinks containers are made from steel. To achieve
these higher targets, it will be important to capture data on all steel packaging recycling.
Paper/Card
4.23 The recycling target proposed for paper/card packaging is 85% by 2030. The high
target reflects that all paper/card packaging will be in scope of Extended Producer
Responsibility (i.e. none under deposit return scheme); that collections of paper/card
packaging for recycling are widespread; and the current recycling rate is high at around
70%, with the recycling rate for non-consumer packaging estimated at around 85% 8. The
ongoing need to review the mixed grade protocols to monitor changes in the mix of
packaging and non-packaging paper is likely to be necessary to help ensure all paper/card
packaging is captured.
4.24 A final decision on targets will depend on final policy decisions for Extended
Producer Responsibility, deposit return scheme and consistent recycling, informed by
responses to the consultations, continued engagement with the relevant materials
organisations and the Advisory Committee on Packaging, and further analysis for the final
impact assessment.
8 Valpak PackFlow Covid-19 Report – October 2020:
8 of 16Meeting recycling targets in England, Northern Ireland, Scotland and Wales
4.25 The Extended Producer Responsibility scheme will operate UK-wide to ensure a
consistent approach for producers. However, as producer responsibility is a devolved
matter and as expressed in the 2019 consultation, recycling targets will be required to be
met and reported on for each of England, Northern Ireland, Scotland and Wales.
4.26 The packaging Extended Producer Responsibility recycling targets (by material
type) will apply in each nation, with the obligation on producers to meet these targets in
each nation. In order to enable the measurement of recycling rates, Government proposes
setting an obligation on ‘sellers’ (see definition of ‘sellers’ and further details of this
obligation in Section 5) to separately report tonnages of packaging placed on the market in
England, Northern Ireland, Scotland and Wales for each of the main packaging material
categories. The first reporting year will be 2024 for packaging placed on the market in
2023, and the first year for which targets will be required to be met for England, Northern
Ireland, Scotland and Wales will be 2025.
Introduction of new targets
New material recycling targets
4.27 Government will consider the introduction of recycling targets for other packaging
materials where it considers targets would help achieve scheme outcomes and provide an
incentive for producers to invest in the collection and recycling of this packaging.
Government proposes in the first instance to introduce targets for fibre-based composite
packaging.
Fibre based composite target
4.28 The collection and reprocessing of disposable paper cups and other fibre-based
composite packaging is limited at present. This is due to the costs of collecting, limited
sorting capacity, the challenges of reprocessing and lower material revenue in comparison
with other paper/card waste-streams.
4.29 Under the current producer responsibility system there is little or no economic
incentive to recycle this packaging. As it falls under the paper/card stream producers
placing disposable paper cups and other fibre-based composite packaging on the market
can comply with their obligations by purchasing evidence of any paper/card packaging
recycling. It also means that there is a lack of accurate placed on the market data and
recycling capture rates for these packaging materials.
4.30 In the 2019 consultation there was majority support for the setting of recycling
targets for single-use disposable cups. Subsequent stakeholder engagement has also
indicated that there is support for a target to apply to other types of fibre based composite
packaging which can also be more difficult to recycle. Government therefore proposes to
introduce recycling targets for a new category of packaging, fibre-based composite
packaging. By fibre-based composite packaging we mean laminated paperboard; either
9 of 16single-sided plastic laminate or two-sided plastic laminate and the packaging may include
other material such as aluminium foil. Examples of fibre-based composite packaging
include disposable drinks cups, sandwich boxes (skillets) and food and drink cartons.
Many of these packaging types cannot be reprocessed in paper packaging mills with
standard reprocessing technology. They are generally required to be separately collected
or separately sorted and reprocessed at specialist mills 9.
4.31 It is estimated that approximately 131,000 tonnes of fibre-based composite
packaging were placed on the market in 2017 10 (excluding cups). Projections for 2023
indicate 107,000 tonnes of fibre-based disposable cups (5.9bn) could be placed on the
market 11. However, data on these packaging types remains limited. Better data on
disposable paper cups and fibre-based composite packaging will be required before
targets can be set, otherwise there is a risk of setting an over or under-challenging target
that could lead to contradictory or inefficient outcomes. Before setting targets,
Government is taking steps to obtain better data.
4.32 Defra has commissioned a piece of research to obtain UK data from industry on
disposable cups and other fibre-based composite packaging, including placed on the
market data, market trends and estimated current recycling rates for these materials. This
evidence is due in 2021.
4.33 Government also proposes to require producers to report tonnages of fibre-based
composites placed on the market as part of the producer reporting obligations set out in
the next section. This reporting requirement would be introduced under the proposed Data
Reporting Regulation 2021 which will require placed on the market data for 2022 to be
reported in January 2023 (see Section 14). Thereafter, reporting of placed on the market
data will be required under the Extended Producer Responsibility Regulations. There may
also be the potential to require collectors, sorters, reprocessors/exporters to report on
tonnages of fibre-based composite packaging collected, received and managed. Data
reported for 2022 and 2023 would inform the setting of targets. It is proposed that
recycling targets would be introduced from 2026.
9Confederation of Paper Industries; Paper and Board Packaging Recyclability Guidelines, Revision One,
January 2020.
10This is an estimate from a waste composition study by WRAP on the tonnage of food and drink cartons
placed on the market. It excluded food/salad boxes and is considerably higher than estimates suggested in
responses to the 2019 consultation (60,000tpa), so is used as a proxy for all (non-cup) based fibre-
composites including food/salad boxes.
11 This is in line with the growth rate proposed by the Environmental Audit Committee
https://publications.parliament.uk/pa/cm201719/cmselect/cmenvaud/657/65705.htm
10 of 16‘Closed loop’ recycling targets
4.34 In the 2019 consultation, whilst 58% of respondents agreed with closed loop 12
recycling targets, many felt this should be a future aspiration once the Extended Producer
Responsibility scheme was established and progress had been made in meeting the new
material recycling targets. Closed loop recycling targets were proposed as a means of
driving improved quality in recyclable materials and thereby encouraging greater use of
recycled materials in equivalent closed loop applications (e.g. recycled plastic packaging
used in the manufacture of plastic packaging).
4.35 Many noted that in setting closed loop targets consideration should be given to the
lifecycle of the material and the cost-benefit impacts. For some materials, such as metals,
there is no additional environmental benefit to be gained from recycling metal packaging
back into packaging applications. Some packaging, such as corrugated card already has
very high levels of recycled content driven by commercial as well as environmental
considerations, and as noted there is already a re-melt target for glass. For other
packaging such as types of plastic packaging, the infrastructure is not yet in place to
enable closed loop recycling to take place with enough volume and quality. Therefore, any
consideration of closed loop targets must be material specific.
4.36 Material quality will be incentivised across the packaging value chain through a
range of measures that are proposed in later sections of this document. Modulated fees
will drive better packaging design and the use of recyclable packaging. All households and
businesses will be able to recycle the same materials. Labelling and consumer information
will provide clear instructions on the packaging that can be recycled. Payment
mechanisms for those providing packaging waste management services will factor in
quality of material, and material standards will apply at sorting and reprocessing stages.
Improved material quality, as well as measures such as the plastic packaging tax, will
stimulate demand for recycled content in plastic packaging.
4.37 Government accepts the argument that these new measures should be fully
implemented as a first step and their impact assessed before additional targets are
introduced. Improved data reporting under the Extended Producer Responsibility scheme
will also help identify where closed loop targets may be required to drive quality and more
recycled content in packaging where this is viable on economic, environmental and
commercial grounds.
4.38 However, as material quality is a concern of stakeholders, Government is seeking
further views on the extent to which the measures identified above are likely to, in the
12'Closed loop’ recycling is generally understood to take place where recycled material substitutes the
equivalent virgin material, regardless of the application (e.g. recycled HDPE plastic packaging used in in the
manufacture of plastic pipes).
11 of 16absence of closed loop targets, meet producers and others’ expectations for improved
material quality. Government is particularly interested in views on plastics but also other
materials such as card and wood. If closed loop targets are not taken forward at this stage
Government would consider these again in 2024/25, with implementation from 2026.
Re-usable and refillable packaging targets
4.39 Government is undertaking work on re-useable and refillable packaging as part of
the review of the Packaging (Essential Requirement) Regulations 2015, the post
implementation review of which began in February 2021. As part of this review we are
looking at how targets or obligations may be placed on producers to encourage waste
prevention and greater use of re-usable and re-fillable packaging.
4.40 The UK Plastic Pact (UKPP) also has work on-going. It consulted pact members in
January 2021 on a reuse/refill target including potential options for setting a target and
how it could be measured (and with what data). One aspect of their consultation focused
on legislative and infrastructure enablers to help create a level playing field for producers,
such as legally binding reuse targets and mandatory reporting.
4.41 Once the outputs of these key pieces of work are available, Government will consult
on specific proposals for re-usable and refillable packaging with a view to introducing
obligations from 2025 onwards. Until then, packaging that is re-useable will be treated in
the same way under the Extended Producer Responsibility regulations as under the
current Packaging Waste Regulations (2007).
4.42 Under the current regulations reusable packaging is handled in a similar way to
non-reusable packaging. It is only counted towards a producer’s obligation on the first use;
once it re-enters the market as a reused item, if sufficient proof that it has been reused can
be provided by the producer, it is not counted towards their obligation.
4.43 We are inviting feedback in this consultation on potential definitions of reusable
packaging and approaches to setting targets or obligations, questions on which are set out
in Annex 1. We also seek views on whether a requirement should be placed on producers,
delivered through the Scheme Administrator, to proactively support market development
and the commercialisation of re-use systems, through direct funding and to encourage
their adoption through modulated fees. Please make sure to refer to this Annex (or below)
if you would like to respond to these proposals.
Annex 1: Refillable/reusable packaging
Definitions
Before we can set any reuse/refill targets in the Extended Producer Responsibility
regulations, a definition of reuse needs to be established. Re-use is not defined in the
Packaging Waste Regulations 2007. Several definitions however do exist including in UK
regulations:
12 of 16The Packaging (Essential Requirements) Regulations 2015 define reuse as13:
“….any operation by which packaging, which has been conceived and designed to
accomplish within its life cycle a minimum number of trips or rotations, is refilled or used
for the same purpose for which it was conceived, with or without the support of auxiliary
products present on the market enabling the packaging to be refilled, and reused
packaging shall be construed accordingly; such reused packaging will become packaging
waste when no longer subject to reuse”
The European Packaging and Packaging Waste Directive (PPWD) was amended in
2018 and defines reusable packaging as:
“packaging which has been conceived, designed and marketed to carry out multiple
trips in its lifetime by being refilled or reused for the same purpose for which it was
conceived”
Annex II of the PPWD states that to be classified as reusable, packaging must meet the
following three criteria:
- A number of rotations are possible in ‘normally predicable conditions of use’
- Processing meets the health and safety requirements for the workforce
- The packaging is recoverable when it becomes waste
The UK Plastics Pact has a target of 100% of plastic packaging to be reusable,
recyclable or compostable by 2025 and adopts the Ellen MacArthur Foundation’s definition
of reuse and reusable packaging 14:
“Reuse is the operation by which packaging is refilled or used for the same purpose for
which it was conceived, with or without the support of auxiliary products 15 present on
the market, enabling the packaging to be refilled.
Reusable packaging: Packaging or packaging component which has been designed to
accomplish or proves its ability to accomplish a minimum number of trips or rotations in
a system for reuse.”
13 https://www.legislation.gov.uk/uksi/2015/1640/pdfs/uksi_20151640_en.pdf
14 ‘Reuse Rethinking Packaging’ Ellen MacArthur Foundation 2019
https://www.ellenmacarthurfoundation.org/publications/reuse
15An auxiliary product is a product used to support the refilling/loading of reusable packaging; - such as a
detergent pouch used to refill a reusable container in the home. These auxiliary products are not considered
reusable packaging
13 of 16Target and other approaches to incentivising use of reusable and
refillable packaging
One of the main themes identified in discussions with the UK Plastic Pact, is that any
target needs to capture packaging that is being re-used; not just the amount of reusable
packaging that is placed on the market. There is no benefit to be gained from switching to
reusable packaging if a packaging item is only used once and then discarded.
Reuse systems can be defined as consumer-owned, where the consumer owns the
reusable packaging and is responsible for washing and using that packaging time and time
again, or business-owned, where businesses are responsible for encouraging consumers
to return packaging items to them and take responsibility for their cleaning and refill.
Several of the large UK supermarket retailers have introduced reuse systems in their
stores, with most of these following the consumer-owned model.
However, the increase in online shopping could mean a move towards more business
owned reuse systems, although this is a more costly option. Developments by the main
UK retailers are currently focused on instore reuse/refill systems. In considering any
target/obligation on producers, both trends in purchasing practices and behaviour, and
different approaches to reuse/refill will need to be considered.
It is also essential that any packaging product that is designed to be reusable is also
designed to be recyclable at end of life.
The PPWD lays out the following options for how targets can be set:
• Quantitative or qualitative reuse/refill targets
• Adjusting recycling targets to account for reusable packaging, by up to 5% per
annum
• Setting a minimum percentage of reusable packaging placed on the market every
year for each packaging stream, with the obligation placed on the producer
In the review of the Effectiveness of the Essential Requirements for Packaging and
Packaging Waste and Proposal for Reinforcement (2020), Eunomia considers that the
final option would not provide a clear demarcation of what can and cannot be placed on
the market, as reaching a prescribed minimum percentage of reusable packaging placed
on the market would depend on the amount of non-reusable packaging placed on the
market.
However, if the reduction in single use-packaging this led to could be calculated, it could
be possible to set this target alongside a reduction target.
Eunomia suggest placing a mandate on reusable packaging being required for certain
products as an alternative option for placing obligations on producers.
The Eunomia review gives three possibilities for reuse systems:
• A closed loop system – in which packaging is circulated by a company or group of
companies
• An open loop system – in which packaging circulates amongst unspecified
companies
• A hybrid system – in which the end-user retains the reusable packaging and uses
auxiliary one-way packaging to refill it. Any target being set around prevention or
14 of 16reuse/refill will need to be long-term, to allow infrastructure to develop to meet any
targets.
The Table below sets out various ways in which a reuse/refill target could be introduced:
Table 4 - Possible approaches to setting reuse/refill targets
Possible approach to targets Pros Considerations
A certain percentage of The obligation would May need to be
packaging that producers place apply to individual complemented by a
on the market each year by producers – so would not reduction target
packaging material or format require complex reporting
How to measure
must be reusable requirements that
national targets demand
Set a packaging reduction Would allow the amount Would require time to set
target. This could be achieved of reuse to be measured up and requires
by producers implementing investment in the
reuse systems in stores, infrastructure
recording data on their uptake
and using this to calculate the
amount of single use packaging
reduced as a result
Adjust the annual packaging This creates the same
waste recycling target for each issues; how do you
packaging material by taking measure if it has been
into account the average share, reused unless businesses
in the preceding three years, of have the infrastructure in
reusable sales packaging place to do so
placed on the market for the
first time and subsequently
reused
Mandate that certain products Potentially easier to How to measure if the
must be packaged in reusable implement, with the packaging is being reused
or refillable packaging obligation on the pack as intended
filler
Reuse/ re-fill targets – examples international approaches
Several European countries have introduced re-use and refillable packaging policies and
have set targets based on the definition of reuse in the PPWD. Most of these schemes are
for drinks containers, where perhaps the basic infrastructure may already be in place in
some countries.
• Romania: from the 1st January 2020, businesses that put packaged goods on the
market must demonstrate an annual average of 5% reusable packaging across all
packaging formats, increasing by 5% per annum every year until 25% in 2025.
• Spain (Navarra region): A regional law introduced in 2018 requires businesses in
the hotel, retail and catering sectors (HORECA) to serve 80% of beer, 70% of soft
15 of 16drinks and 40% of bottled water in reusable containers by 2028. Also, by 2028 15%
of filled beverage containers sold in shops must be reusable.
• France: introduced a law in 2020 to increase the proportion of reusable packaging
on the market to 5% by 2023 and 10% by 2027. The reusable packaging must be
recyclable at end of life.
• Germany: has set a target of 80% of beverage packaging to be reusable
Alongside the law mentioned above, in July 2020 France launched a consultation to
reform parts of their Extended Producer Responsibility system. One of these reforms
included an obligation on some sectors to operate and contribute funds that are dedicated
to financing repair, reuse and refill operations.
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